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CORRESPONDENCE - NON-AGENDA
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City Clerk
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Agenda Packet
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9/1/2020
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SHEET <br />1 <br />3 <br />:45:13 <br />:45:13 <br />:15:13 <br />:45:13 <br />45:13 <br />4 <br />S <br />6 <br />i <br />H <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995.2449 <br />38 PAGE 149 PAGE 151 <br />ON THE THIRD PROJECT AND I, FRANKLY, STARTED TO HATE 1 HURT TO JUST TAKE A RUN AT IT?" I HAD HEARD ROMBLINGS <br />MYSELF FOR HAVING ALLOWED THIS RELATIONSHIP TO CONTINUE 2 THAT THERE WERE ISSUES GETTING IT ENTITLED FOR WOOD <br />AND RELY ON HIS MISREPRESENTATIONS FOR A THIRD PROJECT. 3 FRAME BUT I AGREED TO MOVE FORWARD DESPITE KNOWING THAT <br />Q SO YOU UNDERSTOOD -- DID YOU UNDERSTAND THAT 4 THERE WERE HURDLES HERE. <br />MR. DALESANDRO MAY HAND THOSE CARDS TO THIRD PARTIES? 09:45:13 5 Q WHEN WAS THE DISCUSSION YOU HAD WITH <br />A I DIDN'T KNOW WHAT HE DID WITH HIS TIME. 6 MR, DALESANDRD WHERE HE SAID "LET'S TARE A RUN AT IT"? <br />Q WELL -- 09:45:13 7 A IT WOULD HAVE BEEN EARLY DECEMBER, 2010. <br />A I SPOKE TO HIM ONCE OR TWICE A DAY FOR FIVE, <br />TEN MINUTES AT A TIME AND HE'D GIVE ME SOME CROCK OF <br />SKIT AND I STARTED TO NOT KNOW -- I HAD NO BELIEF IN HIM <br />ANYMORE. I MEAN, YOU ASK THE MAN. NOBODY HAS RIPPED <br />INTO SOMEBODY THE WAY I RIPPED INTO HIM BECAUSE I FELT <br />HE DECEIVED ME. HE MISREPRESENTED HIS ABILITY TO GET <br />THIS DONE PON TWO MONTHS. MY ASS WAS ON THE LINE. I <br />RELEASED, I DON'T KNOW IF IT WAS 200- OR $300,000 <br />DEPOSIT BASED ON HIS REPRESENTATIONS AND I WAS REALLY <br />DESPERATE. <br />Q WHEN DID YOU RELEASE THE DEPOSIT? <br />A I CAN'T REMEMBER. I THOUGHT IT WAS MAYBE IN <br />EARLY JANUARY, IT'S POSSIBLE, MID JANUARY. <br />Q AND WHAT PROPERTY ARE WE TALKING ABOUT THAT <br />THIS DEPOSIT IS IN? <br />A THE MET, VIE AT THE MET PROPERTY. <br />Q AND HOW DID YOU FIND -- STRIKE THAT. <br />DID YOU FIND VDC AT THE MET? <br />PAGE 150 <br />:45:13 1 A RACHEL'S PARENTS LIVE ABOUT A MILE FROM THERE. <br />I HAD SEEN THE SIGN ON THE PROPERTY FOR AT LEAST A YEAR <br />AND A HALF. I THOUGHT IT WAS UNDER CONTRACT WITH TRAVEL <br />PRO. <br />SEAN CALLS ME ONE DAY AND TELLS ME THERE'S A <br />PROPERTY OVER THERE. <br />I SAY "WELL, WHAT'S WRONG WITH IT?" T HAD <br />HEARD THERE WERE SOME ENTITLEMENT ISSUES AND I DON'T <br />EXACTLY REMEMBER WHY OR HOW I CAME TO THE CONCLUSION <br />I'LL TAKE A RUN AT IT BUT IN TERNS OF WHAT YOU COULD <br />ACQUIRE THE SITE FOR I MADE A DETERMINATION THAT IT WAS <br />WORTH All ATTEMPT UNDER THE UMBRELLA OF DUE DILIGENCE TO <br />TAKE A LOOK AT THE DEAL. <br />Q ALL RIGHT. <br />SO YOU SAID MR. DALESANDRO CONTACTED YOU AND <br />:45:13 <br />:45:13 <br />:13 <br />45:13 <br />TOLD YOU THAT, ABOUT THE SITE; IS THAT RIGHT? <br />MR. BISNO: OBJECTION. THAT'S NOT WHAT THIS <br />WITNESS TESTIFIED. <br />Q BY MR. RUBINER: YOU CAN ANSWER THE QUESTION. <br />A WHEN YOU SAY TELL ME ABOUT THE SITE, I <br />TESTIFIED I HAD KNEW ABOUT THIS. THIS DEAL HAD BEEN <br />TAKEN BACK BY THE BANK IN 2008 OR '9. IT WAS UNDER <br />CONTRACT. THE SIGN WAS ALWAYS ON THE PROPERTY. I HAD <br />SEEN THE SIGN MANY TIMES. <br />I WAS TOLD BY SEAN "WELL, JUST WHAT WOULD IT <br />09:45:13 8 Q WHERE DID THE CONVERSATION TAKE PLACE? <br />00:45:13 9 A THERE WAS A TIME PERIOD WHEN ROYAL CANYON FELL <br />10 OUT, SEAN WAS CALLING, I MET HIM ON THIS -- AT THIS CAFE <br />11 ON MELROSE WHERE HE KEPT TELLING ME HE'S GOING TO <br />12 FINANCE DEALS, MAYBE HE'LL FIND DEALS AND HE SENT ME A <br />13 TON OF DEALS. THIS WAS ONE AMONG MANY THAT HE HAD SENT <br />14 TO ME AND I HAD PASSED OFF ALL OF THEM BUT THIS ONE <br />15 STRUCK AN INTEREST IN ME BECAUSE THIS HAD BEEN THE FOCUS <br />16 OF WHERE I WAS TAKING MY BUSINESS. <br />09:45:13 17 Q DID YOU EVER HAVE ANY MEETINGS WITH <br />18 MR. DALESANDRO AT YOUR GOLF CLUB? <br />09:45:13 19 A I THINK HE CAME TO THE GOLF CLUB ONCE. <br />09:45:13 20 Q WHEN WAS THAT? <br />09:45:0 21 A I DON'T RECALL. <br />09:45:13 22 Q WAS IT BEFORE OR AFTER THE CONVERSATION YOU HAD <br />23 WHERE YOU SAID LET'S TAKE A RUN AT THE VDC AT THE MET <br />24 PROJECT? <br />09:45:13 25 A I DON'T KNOW, <br />151 <br />PAGE 152 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />45:13 <br />15:13 <br />15:13 <br />:45:13 <br />:45:13 <br />8 <br />9 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />Q WHERE ON THE GOLF COURSE DID THE CONVERSATION <br />TAKE PLACE? <br />A IT WAS ON THE BALCONY ADJACENT TO THE BAR. <br />Q WAS ANYONE ELSE PRESENT? <br />A T THINK MY BROTHER WAS THERE. I'M NOT ENTIRELY <br />SURE BUT I THINK ED. <br />Q WHICH BROTHER? <br />A JEREMY. <br />Q HO'W LONG DID THE MEETING LAST? <br />A I DON'T RECALL. <br />Q MORE THAN AN HOUR? <br />A I DON'T RECALL. <br />D MORE THAN SIX HOURS? <br />A I WOULD SAY IT WAS LESS THAN SIX HOURS. <br />Q MORE THAN THREE HOURS? <br />A I WOULD SAY IT'S LESS THAN THREE HOURS. <br />Q MORE THAN TWO HOURS? <br />A YOU LIKE TO JUST ASK -- <br />MR. STEED: COUNSEL -- <br />THE WITNESS: GO AHEAD. <br />MR. BIEND: -- I'M GOING TO OBJECT. THIS WITNESS <br />HAS THREE TIMES, PERHAPS FOUR, TESTIFIED HE DOES NOT <br />RECALL. <br />Q BY MR. RUBINER: WAS IT MORE THAN TWO HOURS? <br />A MY 3EST, VERY BEST GUESS IS IT WAS MORE THAN 15 <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. I <br />August 13, 2012 <br />
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